Conflict of Interest Policy

Introduction

Quantace Research and Capital Private Limited ("Quantace") is committed to providing research services that are transparent, unbiased, and free from conflicts of interest. This policy outlines the measures we have implemented to address, manage, and disclose any actual or potential conflicts of interest in accordance with the Securities and Exchange Board of India (SEBI) (Research Analysts) Regulations, 2014.

Objective

The purpose of this policy is to:

• Ensure that the research and analysis conducted by Quantace remains independent and objective.
• Mitigate conflicts of interest that could affect the impartiality of our research reports.
• Ensure that all material conflicts of interest are disclosed to clients, stakeholders, and the public as necessary.

Identification of Conflicts of Interest

A conflict of interest may arise in situations where:

1. Ownership or Financial Interest: Quantace, its associates, employees, or relatives have a financial interest in the securities of a company being researched (the "subject company").
2. Compensation: Quantace has received or will receive compensation from the subject company for providing investment banking, brokerage, or other services.
3. Personal Trading: Analysts employed by Quantace or its associates engage in personal trading of securities that they recommend or analyze.
4. Business Relationships: Quantace has business relationships with the subject company that may influence its research or recommendations.
5. Other Conflicts: Any other situation where the objectivity of the research or recommendations may be compromised.

Managing Conflicts of Interest

To manage and mitigate conflicts of interest, Quantace implements the following controls:

1. Segregation of Research Activities: Research activities are kept separate from other business activities (such as brokerage or investment banking services) to ensure the independence of research.
2. Internal Policies:
   • Analysts are restricted from trading in the securities they analyze or recommend within 30 days prior and five days after the publication of the research report.
   • Analysts and employees are required to disclose any financial interest they have in a subject company, including the ownership of 1% or more of a company's securities.
3. Disclosure of Conflicts:
   • All research reports issued by Quantace will contain disclosures about any conflicts of interest, including financial interests, beneficial ownership, compensation received, or other material conflicts.
   • We will disclose any compensation received from a subject company within the last 12 months for investment banking, merchant banking, or other services.
4. Approval and Monitoring: All research reports are subject to internal review and approval by compliance officers to ensure they meet regulatory standards and are free from undue influence.
5. Prohibition on Insider Trading and Front Running:
   • Analysts and employees of Quantace are strictly prohibited from engaging in insider trading or using unpublished price-sensitive information.
   • No analyst shall engage in front running of any research report or take positions contrary to their recommendations.
6. Gifts and Incentives: Employees and analysts of Quantace are prohibited from accepting gifts or incentives from clients, subject companies, or any external party that could compromise the integrity of research.

Disclosure in Research Reports

Each research report issued by Quantace will include the following disclosures:

• Whether Quantace, its associates, employees, or relatives hold any financial interest or beneficial ownership in the subject company.
• Whether Quantace or its associates have received compensation from the subject company for services in the past 12 months.
• Whether the research analyst has served as an officer, director, or employee of the subject company.
• Any other material conflicts of interest.

Training and Awareness

Quantace ensures that all employees, particularly those involved in research activities, are regularly trained on the conflict of interest policy and their responsibilities under it.

Compliance and Monitoring

Quantace appoints a Compliance Officer who is responsible for:

• Monitoring adherence to this policy.
• Reviewing all research reports for compliance with SEBI regulations.
• Ensuring that potential conflicts are appropriately managed and disclosed.
• Conducting periodic reviews of the conflict management processes to ensure their effectiveness.

Amendments

This policy will be reviewed periodically and amended as necessary to ensure compliance with any changes in regulatory requirements and best practices.

The Research Analyst and employees work in good faith and without prejudice, towards the interests of the Investors.